Overview

• On Aug. 8 the CFPB published four advance notices of proposed rulemaking to reconsider numeric tests defining “larger participants” in the automobile financing, consumer debt collection, consumer reporting and international money transfer markets.
• Each ANPR lists specific threshold options: for auto financing, 300,000, 550,000 or 1,050,000 annual originations; for debt collection, $25 million, $50 million or $100 million in receipts; for consumer reporting, $41 million in annual revenue; and for international transfers, 10 million, 30 million or 50 million transactions.
• CFPB estimates that raising these cutoffs would reduce the number of supervised entities while still covering the vast majority of market volume.
• The bureau says current thresholds impose disproportionate compliance burdens on smaller firms and divert limited supervisory resources as its funding faces a near-50% cut by Congress.
• The public-comment period runs through Sept. 22, after which the bureau may advance formal proposed or final rules informed by stakeholder feedback.